Martin B. Biles 8. -4- Enclosure VI shows the quantity of alpha wastes, assumed to ‘be 2391, dumped into the ocean during the last eight years undor a prozram managed by the European Nuclear Energy Agency. Thus, the Interc tonal roticy is to allow ocean dumping of limited quantities Gr rac:-Guctivity in a controlled fashion and there is an agency to facilitate and coordinate dumping by certain European nations. The added features of the Act and EPA Rega., (compared to International Regulations) which in our experience prohibits only U.S. agencies from putting radioactivity into the ocean, are of questionable value in protecting the ocean environment and are of no wee in golving any waste Ciscosal protlems inthe U.S. These provisions are highly discriminatory agzinst the U.S. considering thet other nations are dumping radioactive wastes into the occan. Ocean dumping by other nations will presuincdly continue since such actions are allowed under the International Reruletiens without eo much ''rcd tape." Forccases such as clearup of“old radioactive facilities and nuclear testing grounds, these resulations are in conflict with our requirement to kcep exposures of people as low as practicable. In this context, U.S. regulations have a negative benefit for U.S. people. As otated by Mr. Wastler in item 3c of Enclosure 1I".... if you have a DEIS which stateg another feasible disposal method, it virtually eliminates one of the requirements for an ocean dumping permit, namely the lack of ak alternate disposal methed."' This statement reveals probably the most serious difference of all between the Act and EPA Regs., and between EPA Regs. and International Regulations. The Act requires that the Administrator (of EPA) shall establish and apply criteria for reviewing and evaluating permit application including locations and methods cf disvosal and land-based alternztives, (see Sec. 102(3)(G) of Enclosure Hil), The Act does not state (if so I cannot find it) that the existence of some cther alternative virtually climinztes the possibility of obtaining a permit. This is an EPA requirement additional to the Act that goes far cutsido the requirements of the <\ct. The International Regulations state that in the environmental assessment that is to be made, consideration is to be given to the "justification for the proposed dumping, when weighcd against land-based altcinatives, "' Thus, the existence of other options, unde: these regulations, does not rule out obtaining an ocean dumping permit if ocean dumping is the bect alternative. The International Rerulations require that participating nations evaluate variouy alternatives and do what is practical and reasonat rye me teow thot emg Det tr ge meee